Tasting room separation from production

[JakeH]

Hi all - odds are that this has been covered quite a lot in the past, but I have a bit of a disagreement between observation in the field and what I am hearing about tasting rooms and how to separate from the production space. 

the guy I am working with to help me with my TTB application is telling me that I MUST have a wall floor to ceiling separating my tasting room from production space and there can not be a door that connects the spaces. 
 

meanwhile several local spots have a bar sitting right in the middle of their production space. Another has a glass wall separating the retail area from production but does have a door right in the middle connecting the space. 
 

I am trying to finalize my plan overall and currently the space looks like the attached with a bar/tasting area and an 8’ tall wall separating production space from that. Both have their own exterior doors. But there is a door connecting them. 
 

it seems to me that common sense would win out and a door connecting spaces in the same building is going to be ok, as long as it is controlled access. But my guy is pretty firm that this isn’t going to be ok.   I really want to keep that door, just for the functionality of the place. 
 

just picking brains here. What in all your experiences would work?  It just doesn’t seem realistic that a building would have to be bisected and no way to get from one side to the other without going outside.  I know many here have much more experience and have actually got real feedback from TTB. So hoping someone would have some credible insight. 
 

 

Permit Drawings Jakes Distillery A-3.pdf

[38°]

We were approved recently and the TTB agent made sure to specifically confirm the seperation was floor to ceiling and secure. We do have a door and she made a point to confirm it was secured with appropriate approved locks.

So, a door is acceptable.

[38°]

One more thing. When you submit, make sure to only show the production/bonded space. As that is the DSP and technically you cannot have a tasting room inside your DSP.  If you show the retail and tasting space, it may slow down the review and they may ask for revised drawings.

[JakeH]

2 hours ago, 38° said:

We were approved recently and the TTB agent made sure to specifically confirm the seperation was floor to ceiling and secure. We do have a door and she made a point to confirm it was secured with appropriate approved locks.

So, a door is acceptable.

Thanks for that bit of insight.  What is meant by approved locks?  Seems that is something can sort out during construction anyway.

was definitely hoping to get awat from floor to ceiling considering my ceilin is 20’, but if you gotta, it is what it is.

[Thatch]

10 hours ago, JakeH said:

Thanks for that bit of insight.  What is meant by approved locks?  Seems that is something can sort out during construction anyway.

was definitely hoping to get awat from floor to ceiling considering my ceilin is 20’, but if you gotta, it is what it is.

The locks that DSPs use to secure outdoor tanks or indoor tanks containing spirits and, the enclosures around outdoor tanks and doors from which access may be gained from the outside to the rooms or buildings containing the indoor tanks or portable bulk containers of spirits, shall meet the minimum specifications in 27 CFR 19.192(f).

Is your entire building going to have a H-3 occupancy?

 

[Thatch]

13 hours ago, JakeH said:

But my guy is pretty firm that this isn’t going to be ok.   I really want to keep that door, just for the functionality of the place. 

The door should be fine.  We have two.  Is he saying this is a TTB issue or a fire issue?

[JakeH]

21 hours ago, Thatch said:

The door should be fine.  We have two.  Is he saying this is a TTB issue or a fire issue?

Saying it is a TTB issue, which I can understand where he is coming from if you read it by the letter of the guidance, but it just doesn't mesh with what is happening in the field at all.

[Thatch]

11 minutes ago, JakeH said:

Saying it is a TTB issue, which I can understand where he is coming from if you read it by the letter of the guidance, but it just doesn't mesh with what is happening in the field at all.

All that I can tell you is we have two man doors and an overhead door between the DSP and an attached warehouse.  All three doors are on the plans submitted to TTB.  Dalkita is a distillery architect and they consult as well.  You might want to give them a call.

https://www.dalkita.com/contact/

Another person who could give you an answer is our former ATF guy, Dave Dunbar dhdunbar1@gmail.com @dhdunbar

I've had the discussion about floor to ceiling and TTB seems adamant on that point.

[Golden Beaver Distillery]

Separate issue, but based on your plans, you might want to study the Sombrero of Death - https://proof33.com/everything-distillers-need-to-know-about-explosion-proofing-and-the-electric-sombrero-of-death/ Not sure of the stack of barrels in the middle of the production area was just for illustration purposes, but you might want to measure the distance from the boiler to the barrels. Boilers are not explosion proof and vapor from those barrels are present within 25' of the boiler per your plans. 

I only mention it was we had to correct a similar condition after we started to setup our equipment.

[JakeH]

17 hours ago, Golden Beaver Distillery said:

Separate issue, but based on your plans, you might want to study the Sombrero of Death - https://proof33.com/everything-distillers-need-to-know-about-explosion-proofing-and-the-electric-sombrero-of-death/ Not sure of the stack of barrels in the middle of the production area was just for illustration purposes, but you might want to measure the distance from the boiler to the barrels. Boilers are not explosion proof and vapor from those barrels are present within 25' of the boiler per your plans. 

I only mention it was we had to correct a similar condition after we started to setup our equipment.

Thanks for that!  My architect just put random barrels in there for illustration.  I am going to put barrels likely in the larger storage area.  I don't think I will have many barrels, but its a small place so I have to be really careful with clearances.